Betabound’s Privacy Policy

Revised – Effective Date June 22, 2017

Centercode Inc., a California corporation, owns and operates the Centercode website (www.centercode.com), the Betabound.com website (www.betabound.com), the web-based test participation portal known as “Betabound™” (my.betabound.com), and the Centercode cloud-based software platform (the “Centercode Platform”). We use Betabound to collect, organize, and announce a wide variety of opportunities to participate in alpha, beta, and field tests (collectively, “Customer Validation Tests”) of the products and services of third parties. We also use Betabound to register and collect information about account holders (“Betabound Community Members”) interested in participating in Customer Validation Tests. Finally, we use Betabound and the software behind it, the Centercode Platform, to perform Customer Validation Tests on behalf of our clients who hire us to conduct, manage, or assist with their Customer Validation Tests. The Centercode Platform is also used by many other companies (also Centercode clients) to develop and manage their own test communities and to conduct and manage their own Customer Validation Tests.

We greatly respect your privacy. We provide this privacy policy to explain what information we gather about you, how we gather it, how we use it, how we share it, how we protect it, and how you can participate in its protection. You should read this entire privacy policy. If it is not acceptable to you, then you should not use our sites or services or submit any personal information or other content to us. By using our sites or services and/or providing data to us you are accepting and agreeing to the practices outlined in this privacy policy. You can request a copy of this privacy policy by contacting us at privacy@betabound.com.

1. Scope of This Privacy Policy

This policy describes our privacy practices in relation to information that we collect (i) through Betabound.com, the Betabound web-based portal, our Betabound social media pages, emails, and other communications that we have with you related to Betabound, both online and offline (collectively, the “Betabound Sites”), and (ii) from testers participating in Customer Validation Tests conducted on the Centercode Platform and through from emails and other communications with testers, both online and offline. This policy does not describe our privacy practices related to Centercode.com, and our Centercode social media pages, emails, and other communications that we have with you related to Centercode, both online and offline (collectively, the “Centercode Sites”). If you are a visitor to the Centercode Sites, please visit www.centercode.com/privacy to learn about our privacy practices that apply to you.

This policy does not supersede or modify provisions in any services agreement between Centercode and any Centercode client relating to the information that we receive or handle on behalf of that client in our role as service provider. This policy does not apply to the practices of third parties that we do not own or control, including third parties with Customer Validation Tests announced on Betabound.com or Centercode clients. Please note that we are not responsible for the privacy policies and collection, use, and disclosure practices (including the data security practices) of these third parties, including third parties that are our clients.

2. The Data We Collect or Process and How We Collect It

In order to enable your use of the Betabound Sites and the Centercode Platform, operate the Betabound Sites and Centercode Platform, provide services to our clients, operate our business, and for other purposes described in this privacy policy, we receive and collect (directly or through our third-party service providers) certain information from you, including Personal Data and User Content. For purposes of this privacy policy: (i) “Personal Data” means any information that identifies you as an individual or that relates to an identified or identifiable individual (e.g., name, email address, phone number, location data, mailing address, etc.); and (ii) “User Content” means any data or materials, including files, text, images, video, and other content you post or upload to the Betabound Sites or Centercode Platform, which may include Personal Data. If you submit any Personal Data or User Content to us, you represent that you have authority to provide us with that Personal Data or User Content and that we have all necessary authorization to use this information in accordance with this privacy policy, even if the information relates to other individuals or entities. You are solely responsible for the contents of the data that you provide to us.

a. Information You Provide as a Visitor to the Betabound Sites or Offline

When you request more information or otherwise contact us through the Betabound Sites or offline (e.g., when you request a free trial or demo, register for a webinar, download whitepapers or other content, complete a contact form, attend one of our events, or email or call us), we collect Personal Data, such as your name, title, company name, job function, address, telephone number, email address, and other Personal Data, User Content, and information that you voluntarily provide to us. We also collect the time, date, and location of the form you submitted.

b. Information You Provide as a Betabound Community Member

If you create a Betabound Community Member account, we require you to provide Personal Data, including your first and last name, email address, username and password, time zone, country, date of birth, and similar basic Betabound Community Member account creation information. In addition, to complete your Betabound Community Member profile, we ask for other Personal Data such as your address, phone number, gender, languages spoken, home ownership information, number of adults and children in your household, information about your education and degrees, employment status and history, job title, employer details, salary, and similar data. We also require you to provide details regarding your experiences with technology and alpha, beta, and/or field testing, the amount of time you have available to participate in a test, and details regarding any products or services you own which may relate to products or services that may be available for testing (e.g., personal computers, cell phones, and other devices). Not all information is required in order to complete the registration and Betabound Community Member profile process, but supplying the additional data can increase the number of test opportunities available to you. After you register and complete your member profile, we also may ask you to complete voluntary surveys where we ask you to provide more details (including additional Personal Data), about your interest in and qualifications for tests being conducted or considered by Centercode clients or other details that may enhance your ability to be selected for tests that a Centercode client may conduct in the future by matching your information with the test participant requirements those tests. Becoming a Betabound Community Member is entirely voluntary. If you do not wish to provide required information, you should not become a Betabound Community Member. If you do not wish to provide any optional additional requested information, you should not do so.

c. Information You Provide as a Prospective or Actual Test Participant

Whether you are a Betabound Community Member or not, it is veryimportant that you understand that if you respond to an email seeking test participants, apply to serve as a test participant, or are selected to serve as a test participant in a Customer Validation Test that we are conducting on behalf of a Centercode client, that a Centercode client is conducting itself using the Centercode Platform, or that any other third party has announced through Betabound, all information that you provide in the course of registration and qualification for, and participation in that Customer Validation Test is controlled by and belongs to a third party and not Centercode or Betabound. If the third party conducting the test is a Centercode client, we have access to, and process, this information at our client’s direction as our client’s service provider.

The nature of the information collected is determined by the party conducting the test. It is not possible to list all types of information that might be collected by the party conducting the test. However, tests often request or require you to provide your name, email address, username, password, date of birth, time zone, physical address, phone number, gender, employer, position, professional life data, personal life data, connection data, location data, preferences, opinions, feedback, product or service usage data, product suggestions, photographs, audio, video, and other types of information and test data. In addition, the test often involves a product, service, or application that directly gathers information, including your Personal Data, during your use. You are providing this data directly to the third party manufacturer of the product, service, or application or its affiliate or agent.

Depending on the nature of any Customer Validation Test, it is possible that in some instances the Personal Data collected by the third party during the test or through the product, service, or application being tested, might include sensitive personal data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, data concerning health or sex life and sexual orientation, genetic data or biometric data. Itisimportantforyoutorememberthattestparticipationisvoluntary. Ifyoudonotwishtoprovidetheinformationrequested, donotparticipateinthetestorusethetestproduct, service, orapplication.

Please remember that while the paragraph above provides basic information about data collection by third parties generally during Customer Validation Tests, the data collection and privacy practices of all third parties (including our clients) are not covered by this privacy policy, and rather are covered by the third party’s privacy policy and/or other agreement(s) you may enter into in connection with a test, which you should read carefully prior to providing any Personal Data or User Content in connection with a test.

d. Information You Provide as a Third Party Announcing a Test on Betabound.com

When you provide information to us to announce your third-party Customer Validation Test, we may collect, process, and use the Personal Data and User Content that you provide to us such as your name and address, work contact information, details regarding your company, your product or service to be tested, your primary audience, your timeframe, and the test you intend to conduct, any test qualification requirements and tester incentives, your URL, and other information that you voluntarily provide to us. You represent that you have authority to provide us with the Personal Data or User Content that you supply and that we have all necessary authorization to use this information in accordance with this privacy policy and post the information you provide to us for posting on the Betabound Sites, even if the information relates to other individuals or entities. You are solely responsible for the contents of the data that you provide to us.

e. Other Information Collected

We may collect information from other sources, such as public databases, joint marketing partners, social media platforms, and from other third parties in order to enhance our ability to provide relevant offers and content to you. We may also collect, track, and analyze non-identifying statistical, anonymous, or aggregated information from visitors and users of the Betabound Sites and Centercode Platform. In addition, we passively collect data, as disclosed below in our policy regarding cookies, IP addresses, and other passive information collection.

3. How We Use and Share Personal Data

a. Generally

We do not rent or sell your Personal Data to third parties for the purpose of marketing their products and services to you. At no time, except as may be required by law or disclosed in this privacy policy, will we share or distribute your Personal Data to third parties or use your Personal Data in any manner not disclosed in this privacy policy. We may use your Personal Data in any of the ways described in this privacy policy, including:

to create an account you have requested on one or more of the Betabound Sites or the Centercode Platform;

to send administrative information about the Betabound Sites or Centercode Platform to you, such as changes to our terms, conditions, and policies;

to respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information about our services and business;

to service your account;

to communicate with you and provide you with all necessary or helpful information about any Customer Validation Test;

to send, install, remove, or retrieve any test product, device, or software in a test being conducted by our client that you have volunteered to participate in;

to personalize your experience on the Betabound Sites and Centercode Platform, such as by presenting opportunities or content tailored to you;

for our internal business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying the Centercode Platform and our Betabound Sites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating or expanding our business activities;

as we believe to be necessary or appropriate under applicable law, including laws outside of your country of residence, to comply with legal process, to respond to the requests of courts or governmental authorities, to enforce our terms and conditions, to protect our operations, rights, privacy, safety, clients, or property (or that of others), and to allow us to pursue available remedies or limit damages we may sustain;

for other purposes you have specifically agreed to;

in the ways described below.

b. Visitors to the Betabound Sites and Business Contacts

We use contact information that you have provided as a visitor to the Betabound Sites or business contact in order to contact you to discuss your interest in Betabound and our offerings and services, and to send you information such as announcements of opportunities and events regarding Betabound and Customer Validation Tests. Where you provide us with your contact information, we may also send you community newsletters, updates, and blog posts. If at any time you no longer wish to receive these communications, you can follow the instructions on opting out in Section 6 below.

c. Betabound Community Members

When you provide your email to us when registering as a Betabound Community Member, you are agreeing to allow us to use the information you provide to determine if you may match the profile required for participating in Customer Validation Tests to be conducted by or on behalf of Centercode clients. When we believe you might be interested in our clients’ Customer Validation Tests, we will contact you about these opportunities. This is the primary function of the information we collect through Betabound. We may also send you newsletters, announcements, or communications, including by email and text message, that we believe may be of interest to you. If at any time you no longer wish to receive any announcements about these test opportunities or other communications or wish to modify your subscription preferences, you can follow the instructions on opting out in Section 6 below to either modify your preferences or terminate your Betabound Community Member account.

Unless and until you express interest in participating in, accept an invitation to participate in, or actually participate in a Customer Validation Test being conducted by or on behalf of a Centercode client, we will not share your Personal Data in any way that identifies you to any Centercode client or other third party. However, when and if you express interest in participating in, accept an invitation to participate in, or actually participate in a Customer Validation Test being conducted by or on behalf of a Centercode client (e.g., when you click on a button or link in an announcement on Betabound.com or in an email to you about a Customer Validation Test that directs you to a test conducted on Betabound or the Centercode Platform), you are agreeing to allow us to share your Personal Data and other information you have provided to us through any Betabound registration or in any other Betabound qualification survey, community survey, questionnaire, form, email or other communication, with the Centercode client conducting the Customer Validation Test. We provide this data in order to enable our client to make selections of possible participants, and for this client to use this data as a part of its test data if it ultimately selects you as a test participant. The client agrees not to use the Personal Data that we share with it in identifiable form for purposes other than the Customer Validation Test you are participating in unless you agree that they may do so. For example, they agree they will not use the contact information we share with them to market or solicit their products or services to you unless you agree to allow this.

d. Customer Validation Test Data

Where you participate in a Customer Validation Test, the data collection and privacy practices of the third party conducting the test (such as those disclosed in its privacy policy and/or other agreement(s) you enter into in connection with the test) control. You should read these documents carefully prior to providing any Personal Data or User Content in connection with a test so that you understand how your Personal Data and User Content will be used and shared by this third party, including third parties who are Centercode clients. In addition, where you participate in a video chat, group discussion, or similar group communication in connection with your participation in any Customer Validation Test, certain profile information associated with your account, such as your username and in some circumstances your first and last names, and any User Content you opt to provide in these group settings, may be visible to other users participating in the same group setting.

We access, collect, store, retain, transfer, use, or otherwise process our clients’ test data, including the Personal Data and User Content that you submit in connection with our clients’ tests, only for the limited and specific purposes requested by our clients and in compliance with our services agreements with our clients, or to prevent or address technical problems or as required by law. We do not own or control this data. You grant us permission, as our client’s service provider, to contact you and to process your Personal Data and User Content provided in connection with our client’s test. In addition, if you are a Betabound member, you agree and understand that we may use information regarding your general level of participation in tests to assist in determining whether you are a good candidate for other tests being performed by our clients.

e. Betabound.com Customer Validation Test Announcement information

When you provide information to Betabound to announce your third-party Customer Validation Test, we make this information available to the public through Betabound.com. Please do not provide any information that you do not want to reveal to the public at large.

f. Third Party Agents and Service Providers

We contract with third party agents and service providers to provide services to us in accordance with our instructions (e.g., data center or hosting, web analytics, shipping, marketing assistance, test product installation, etc.). These third parties may have access to your data (including Personal Data and User Content) if there is a legitimate reason to do so solely for the purpose of providing services to us and in compliance with our instructions. We diligently choose these third party service providers and seek to require the agent or service provider to maintain the privacy, confidentiality and security of the information.

g. Social Media Pages

Information that you disclose on our social media pages will appear in public ways, such as through search engines or other publicly available platforms. Please do not post any information that you do not want to reveal to the public at large. These pages include features such as the Facebook like button. If you use these features, they will collect your Internet Protocol (“IP”) address (a number automatically assigned to the computer that you are using by your Internet Service Provider) and which page you are visiting, and set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing the feature, not by this privacy policy.

h. Business Transactions and Affiliates

In some cases, we may buy or sell assets or businesses, or engage in company transactions such as reorganizations, mergers, joint ventures, assignments, financings, dispositions of stock, and other changes of control, where Personal Data and User Content is transferred to third parties for legitimate purposes in connection with the transactions.

i. Aggregated or Anonymized Information

We may use and share aggregated data or Personal Data otherwise stripped of identifying characteristics for any purpose, except as otherwise prohibited under applicable law.

4. Cookies, IP Addresses, and Other Passive Information Collected

Like many companies, we use cookies (small data files stored on your computer), logging, and similar tools to collect and analyze information about you and the usage of the Betabound Sites and the Centercode Platform. This information is used to operate the Betabound Sites and the Centercode Platform, prevent fraud and misuse of our services, measure how people use the Betabound Sites and the Centercode Platform, analyze how people respond to our emails and other communications, analyze trends, improve the Betabound Sites and the Centercode Platform, and improve your overall experience. We currently use the following third-party cookies:

Google Analytics – These Google-placed cookies allow us to analyze how our visitors and users interact with the Betabound Sites. The information generated about your usage is transmitted to Google in the United States. This information is used to compile statistical reports on activity on the Betabound Sites to help us improve the Betabound Sites and your experience. The information we receive from Google Analytics is aggregated data and we cannot use it to individually identify any particular visitor or user. We encourage you to read the Google Privacy Policy.

Marketo Cookies – These Marketo-placed cookies help us to understand your interactions with the emails and other communications we send you, track your visits to the Betabound Sites (including the dates and times of your visits), and provide you with information that may be of interest to you about our services and business. This information generated about your usage is transmitted to Marketo in the United States. For example, Marketo cookies let us know whether our emails have been opened, which links are clicked, and how many unique visitors we have. The information we receive from Marketo cookies and tracking technologies does not, standing alone, personally identify you. However, if you have chosen to identify yourself to us, such as by providing personal information when filling out a web form, or verifying your email address with us to create an account, we may re-associate this information with the personal information you have provided to us. We encourage you to read the Marketo Privacy Policy.

These third party services may work by use of other standard technologies, such as web beacons, web bugs, clear gifs, and similar tracking technologies.

If You Access Your Account – If you are accessing your account on the Centercode Platform or Betabound, we use mandatory session cookies in order for you to access your account and to secure your account. These cookies allow us to uniquely identify you following entry of your username and password so that you may access your account. In addition, when you log into these accounts, our servers automatically log your IP address, a unique device identifier (a UUID), device name, operating system type and version, network type, country of origin, and information about how you use your account (e.g., the pages you view, the links you click, the dates and times of your requests and referral URL, and other actions you take), what error messages you receive or problems you encounter, and similar data. We use this information to provide our services and support if needed, to monitor the regions from which you navigate your account, to enhance our security, to identify you when you are using your account, and to create de-identified or aggregate information about our users.

In addition, our clients may use cookies and similar technologies in their implementations of the Centercode Platform. Your participation in a test being conducted by a Centercode client on its implementation of the Centercode Platform is governed by the privacy policy of that third party, not by this privacy policy.

Opting Out – If you don’t want data collected and reported by Google Analytics, you can learn more about opting out of Google Analytics here, and can install the Google Analytics Opt-out Browser Add-on. In other circumstances, you can choose whether to accept cookies by changing the settings on your browser. To learn generally how to opt out of cookies using your browser settings and other tracking technologies, you may wish to visit https://www.consumer.ftc.gov/articles/0042-online-tracking and/or http://allaboutcookies.org (third party sites). Opting out of all cookies will prevent you from being able to log into any account you have on the Centercode Platform or Betabound and may impact the functionality you receive when visiting the Betabound Sites.

Do Not Track – Although we do our best to honor the privacy preferences of our users, we are not able to respond to “do not track” signals from your browser.

5. Security

We take the security of your Personal Data very seriously. We maintain a written security program for the security, integrity and protection of the Personal Data we hold against unauthorized disclosure or loss. We have put in place physical, technical, and organizational processes and measures designed to safeguard the Personal Data that we hold. When accessing the Centercode Platform or an account on Betabound via a supported web browser, Secure Socket Layer (SSL) technology protects information using both server authentication and data encryption to help ensure data is safe and secure in transit. We also have implemented an advanced security method based on dynamic data and encoded session identifications and host the Centercode Platform, including Betabound, on servers located in a secure data center environment using a firewall and other advanced technology to prevent interference or access from outside intruders. We require unique usernames and passwords for account authentication.

These safeguards help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of data. However, you should be aware that no security procedures or protocols are guaranteed to be 100% secure, and there is always some risk assumed by sharing information. Betabound Community Members and Centercode Platform users are responsible for maintaining the confidentiality and security of their username and password. If you have reason to believe that your interaction with us is no longer secure, your account has been compromised, or have any other concern regarding our privacy practices, please immediately notify us at privacy@betabound.com. In the event that any Personal Data under our control is compromised as a result of a breach of security, we will investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws and regulations.

6. Opting Out

Betabound Community Members may modify subscription preferences in the member profile to unsubscribe from emails announcing Customer Validation Tests conducted by Centercode clients themselves through the Centercode Platform. To opt out of receiving other emails or communications from us, please contact us at optout@betabound.com. We will respond promptly. If you would like to limit the use or disclosure of your Personal Data collected or stored by us, please notify us at privacy@centercode.com so that we may consider and respond to your request in accordance with applicable law.

7. Data Retention, Modification and Deletion

We will only retain your Personal Data until the purpose for which it was collected has been accomplished or as otherwise required or permitted by applicable law, internal data retention policies, and, in the case of client test data, our services agreements with our clients. Betabound Community Members and users of the Centercode Platform may log in to their accounts to delete or amend certain types of Personal Data and User Content at any time using the functionalities provided. Depending on your location, you may have certain rights to access other Personal Data, or to request that your Personal Data be rectified, amended, deleted, or blocked, as provided by applicable law. If you wish to exercise such rights, please contact us at privacy@betabound.com. For your protection, we may need to verify your identity before implementing any request. We will respond to your request promptly, and in no event later than 30 days from your request, subject to applicable law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions or Customer Validation Tests that you began prior to requesting such account modification or deletion. Deleted or updated Personal Data and User Content stored in our backup systems will be automatically deleted or updated during our backup procedures, except as otherwise required by applicable law. Please remember that Personal Data submitted in connection with a Customer Validation Test is owned and controlled by a third party, and not Centercode.

8. Links to Third Party Sites

The Betabound Sites contain links to other websites on the Internet. For example, on Betabound, we collect and organize a wide variety of Customer Validation Test opportunities from all over the world, so we often announce beta test opportunities for third parties, including those that are our clients and those that are not our clients. When you express interest in participating in, accept an invitation to participate in, or actually participate in one of these third-party tests (e.g., when you click on a button or link in an announcement about a Customer Validation Test), or when you leave the Betabound Sites, it is important for you to know that you are providing information to a third party. In addition, when you participate as a tester in a Customer Validation Test, you may receive third party links related to that test in communications through the Centercode Platform or otherwise. We encourage you to review the privacy policies of all such third parties and any agreement(s) that you enter into in connection with any Customer Validation Test. Please note that we are not responsible for the privacy policies and collection, use, and disclosure practices (including the data security practices) of these third parties, including third parties that are our clients.

9. International Transfer of Data

The Personal Data and other User Content we collect from you, or that our clients collect from you using our services or the Centercode Platform, is used, stored, and/or processed by us in the United States. In addition, in the circumstances described in this privacy policy where your Personal Data and other User Content is transferred to a third party (including our client), this data may also be used, stored, and/or processed outside of the United States in any country in which the third party has facilities or engages service providers. Therefore, by using the Betabound Sites, by participating in any test conducted on Betabound or the Centercode Platform, or disclosing Personal Data or other User Content to us, you expressly consent to the transfer of your Personal Data and other User Content to the United States of America and any other country as described in this paragraph, which country or countries may not offer the same legal protections offered in your country or the country in which you were located when you initially provided the information, and which may be deemed by your country to offer insufficient legal protections. You have a right to withdraw this consent, and you may do so by contacting us at privacy@betabound.com. The withdrawal of consent will not affect the lawfulness of actions based on your consent prior to your withdrawal of consent.

10. Data of Children

The Betabound Sites and the Centercode Platform are not intended for use by minors under the age of 18. We do not knowingly or specifically collect information from minors under the age of 18 through the Betabound Sites or the Centercode Platform. If you believe that we have mistakenly or unintentionally collected or are holding information about minors under the age of 18, please notify us at privacy@betabound.com so that we may investigate and delete the information from our servers as necessary. We comply and require our clients to comply with all legal requirements, including those regarding parental consent if applicable, where a Customer Validation Test hosted on the Centercode Platform involves the collection of information about minors under the age of 18. If you have any questions or concerns regarding the use of the Centercode Platform to collect information about minors, please contact us at privacy@betabound.com.

11. Changes to Our Privacy Policy

We reserve the right to change this privacy policy. If we make changes to this policy, you will find the revised privacy policy posted on the Betabound Sites, along with the effective date of the revised privacy policy. Your use of and access to the Betabound Sites and the Centercode Platform after any changes become effective will be considered your acceptance of those changes and will constitute your agreement to be bound by the new or modified privacy policy.

12. Questions or Concerns?

Questions about this privacy policy or our information practices should be directed to our team by emailing privacy@betabound.com or by mailing us at 23332 Mill Creek Drive, Suite 260, Laguna Hills, CA 92653 ATTN: Privacy Policy.

Games for consoles or computer systemsPhysical products such as remotes, headsets, or smartphonesApps or games that are designed for mobile devices (phones, tablets, etc.)Programs you install on your computer or deviceSoftware, hardware, or services designed for televisionsSites or applications that you access through a web browser (IE, Chrome, Firefox, etc.)Products intended for use by companies or professionalsProducts intended for use by developersProducts intended for personal or home useRequires completion of a qualification questionnaire to verify eligibilityRequires a key code in order to join this betaGet notified when this beta is accepting applicantsInterested participants are free to join immediatelyBeta access is given to customers who purchase the productCurrently recruiting beta testersWill begin recruiting beta testers within the next few weeksDoesn’t have a scheduled start date yetExclusive beta opportunities for Betabound membersBeta opportunities not managed by Betabound, though similar in structureBeta opportunities found from other sources